SCHEDULES

SCHEDULE 2Qualifying asset holding companies

PART 7Treatment of certain amounts payable by a QAHC

51Deeply discounted securities

1

Section 409(2) of CTA 2009 (postponement until redemption of debits for close companies’ deeply discounted securities) does not apply to a qualifying debit.

2

For the purposes of this paragraph, a debit is “qualifying” if—

a

it is a debit in respect of a deeply discounted security of the QAHC that relates to the amount of the discount,

b

the QAHC is party to the security for the purposes of its QAHC ring fence business, and

c

the discount to which the debit relates is referable to an accounting period during which the QAHC is a QAHC.

3

Where a QAHC is party to a deeply discounted security partly for the purposes of its QAHC ring fence business and partly for another purpose, sub-paragraph (1) applies only to the proportion of the qualifying debit that is attributable to the QAHC ring fence business (apportioned on a just and reasonable basis).

4

In this paragraph—

  • “debit” is to be construed in accordance with Part 5 of CTA 2009;

  • “deeply discounted security” has the meaning it has in Chapter 8 of Part 4 of ITTOIA 2005 (profits from deeply discounted securities) (see section 430 of that Act);

  • “the discount” has the meaning given by section 406(3) of CTA 2009.